In ACLU-NJ ex rel. Miller v. Twp. of Wall, 246 F.3d 258 (3d Cir. 2001), future Justice Samuel Alito wrote for a unanimous panel of the Court of Appeals for the Third Circuit that plaintiffs lacked taxpayer standing to challenge a Christmas and Hanukkah display when the municipal expenditure was de minimis (very small), and plaintiffs lacked non-economic standing when there was lack of proof of actually seeing the display at issue.